OSHA Form 300: How to Record Pre-existing Injuries

Posted on 6/5/2012 by James Griffin

Q. If I have an employee who has a pre-existing injury from something non-work-related, but she becomes reinjured while doing her job, do I have to record the injury?
A. The Occupational Safety and Health Administration (OSHA) requires employers to record each fatality, injury, and illness that is:
  1. A new case, and
  2. Work-related, and
  3. Meets one or more of the general recording criteria at 29 CFR 1904.7
[29 CFR 1904.4]
Defining Different Types of “Work-Related” Injuries
Today, we’ll focus on the second trigger: the injury must be “work-related.” In most cases, this is fairly straightforward, but it may become confusing when an injury that occurs at work is a result of a pre-existing condition that occurred outside of work.
Let’s do an example. Let’s say that John injures his shoulder playing softball with his friends on Saturday. He comes into work on Monday and begins his work shift and is initially able to do his job. After he’s been working for a couple hours, however, he wrenches his shoulder lifting some heavy boxes and has to take off work for the next week to recover. Would John’s injury be considered work-related if his shoulder was known to be previously injured from a non-work-related incident?
In this case, yes, it would need to be recorded. If a pre-existing injury or illness is “significantly aggravated” by an exposure in the work environment, then that aggravation makes the recurrence of the injury or illness a new case of a work-related injury/illness.
Pre-Existing Conditions Can Be “Significantly Aggravated”
A pre-existing injury has been “significantly aggravated” when an event or exposure leads to one of the following:

  • One or more days away from work, days of restricted work, or days of job transfer,
  • Medical treatment or a change in medical treatment,
  • Loss of consciousness, or
  • Death.
[29 CFR 1904.5(b)(3)-(4)]
In John’s case, his pre-existing shoulder injury alone wouldn’t have required him to take time off work. However, when he lifted the boxes for his job, that activity aggravated his injury to the point where he had to take time off from work, making his injury work-related and creating an incident that must be recorded on the OSHA 300 log.
Avoid Recordable Injuries with Better Communication
Let’s do another example, this time of an incident that will not be recorded. On Sunday, Jane hurts her knee skiing. Before work begins on Monday, she informs her supervisor of the injury and is reassigned to do paperwork instead of physical activity for a few days.
A day of restricted work or job transfer as the result of an injury is usually recordable. However, as this reassignment occurred before any occupational exposures could aggravate Jane’s condition, her injury is solely the result of outside factors and, therefore, her case is not work-related and does not need to be recorded on the OSHA 300 log.
What difficulties have you found in determining a work-related injuries? Do you have any advice or tips for filling out the OSHA 300 log?

Tags: osha, reporting and recordkeeping

Find a Post

Compliance Archives

Lion - Quotes

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops.

Stephanie Gilliam

Material Production/Logistics Manager

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

Download Our Latest Whitepaper

Just starting out with shipping lithium batteries? The four fundamental concepts in this guide are the place to start.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.